Where do private ETD Providers fit in the QCTO?

Where do private ETD providers fit into the QCTO? In order to answer this question we need to dissect the QCTO system.

This article was meant for the members of The Mentoring Network, but Tim de Bruyn’s notes (‘Is Umalusi a rip-off?”) and the responses to the notes made me decide to share it more widely.

The bomb exploded in 2007 when some consultants and the GTZ (now Deutsche Gesellschaft für Technische Zusammenarbeit (GIZ)) started informing SETAs and other stakeholders in occupational education, training and development (OETD) about the QCTO. The general perception was that the ETQAs would be closed down even though the consultants denied that this would happen. Some SETAs and other bodies who now would probably deny it aggressively fought the establishment of this new body. Some ETQA managers even jumped ship. There were also a number of entrepreneurs (or are they opportunist?) who quickly recognised the opportunities in what was happening, so they joined the club.

Private training providers were not really alarmed at what was happening back then, and rightly so, because it was not really the QCTO that threatened their future existence, but rather a medley of environmental changes, such as the Minister of Higher Education and Training’s NSDS III objectives, the refusal of the CHE/HEQC to recognise unit standards, the complicated QCTO system, the poor performance of students at universities and public FET colleges and the unethical practices of some private learning institutions.

But let me get to the point – the question is “Where do private ETD providers fit into the QCTO?” In order to answer this question we need to dissect the QCTO system.

Arguably the hub of the QCTO system is the Development Quality Partners (DQPs). DQPs are responsible for writing curriculums. It is claimed that they will develop qualifications, but in my opinion they can’t and won’t, but this is a different story that we can, perhaps, discuss some other time. DQPs are required to liaise closely with the industry, i.e. the people who should raise skills needs, as well as with all other stakeholders in skills development, including learning institutions, organised labour, professional bodies, etc. This means that scoping will be, actually already is, an important part of qualifications design. Stakeholders must agree about the contents of curriculums, i.e. what knowledge and skills should be included in a particular qualification. DQPs are established once they are accepted by the majority of stakeholders in a particular field and approved when they close a service level agreement (SLA) with the QCTO. In practice DQPs will be relatively large organisations with sufficient funds to sustain their operations. They will probably come from the current SETAs, although any organisation can become one if they meet the requirements. It is, however, highly unlikely that private providers will meet the requirements to become DQP’s for obvious reasons, so we can rule this out.

The second structure that private providers should consider is the Occupational Qualifications Development Facilitators (OQDFs). OQDFs must meet certain competency criteria and demonstrate that they have the capacity to act as facilitators. This can be achieved by attending formal training in the curriculum writing process offered by a qualified OQDF. They are individuals who register with the QCTO as such. DQPs may not write curriculums without the supervision of an OQDF. Some of the consultants who were involved with the establishment and structuring of the QCTO saw in this an opportunity so that they became ODQPs. They offered workshops on the new curriculum format and writing process but do not easily allow others to join their ranks, even though a substantial number of people attended their workshops and know the process. The result of this is that the writing of curriculums is progressing extremely slowly at the moment because the (some twelve) OQDFs cannot cope with the demand for new curriculums. The QCTO is aware if this and it is their intention to expand the number of ODQPs in the near future. Criteria are being written for registration as ODQP and one can imagine that it will not only include knowledge of the QCTO curriculum model but also knowledge and experience in learning programme design and development. This is one area where some private providers might find a new niche.

An area over which private providers will have almost no control but which offers some opportunities for individuals who are willing to become expert in the field is the Organising Framework for Occupations (OFO). However, the OFO is becoming more a “filing system for jobs” rather than a bridge between skills needs in the workplace and learning programme design and development. It is hoped that this will be rectified by the National Occupation Pathways Framework (NOPF), which is intended to be an articulation route between skills needs and qualifications. This structure is still in its infancy and those with the required knowledge and skills can approach the QCTO to become involved.

The fourth area that deserves attention is the Assessment Quality Partners (AQP). AQPs will be responsible to oversee accreditation of assessment sights, assessment centres, the conduct of assessment and moderation of summative assessments. The design and development of assessment specifications will be done by DQPs in cooperation with AQPs. The criteria for the establishment of AQPs are similar to the criteria for DQPs, and it is possible that the same person or organisation can develop both. This implies that DQPs will identify and recommend AQPs. Like DQPs the AQPs must also have credibility with the stakeholders in OETD, must be financially viable to conduct assessments nationally, since this function will be delegated to the AQPs by the QCTO. AQPs can be free structures/bodies, but it is unlikely that private providers, especially the smaller ones, will meet the requirements for an AQP. Some professional bodies might meet the requirements although it is currently debatable if the AQP concept is financially viable, bearing in mind the proposed QCTO fee structures (way too expensive).

On the issue of finances and fee structures – as the quality assurance body for the entire South African workforce it is inevitable that the QCTO will be a resources hungry structure. The government probably did not foresee this when they established the body and they still do not understand that the QCTO cannot operate on the same budget as the CHE/HEQC and Umalusi. Furthermore, skills levies are paid by the industry, i.e. employers, and it is only logical and fair that skills levies should be used to satisfy the skills needs of the industry. A much bigger part of the skills levies should be channelled to the QCTO than what is currently happening. The idea to use skills levies to build capacity in public FET colleges and universities will probably not work. The Mail and Guardian of 18 to 24 November 2011 report on the fruitless expenditure by government on building capacity in universities, and I see no reason why this will change. Although they will probably not openly admit it, DHET, SAQA, QCTO, CHE/HEQC, Umalusi and the SETAS know this, but they still go along for reasons that we might discuss in a different article. Some SETAs are already supporting the QCTO financially, which shows a good understanding of the occupational learning environment.

Back to the AQPs – private providers will probably not be able to establish such bodies, but they can become involved as assessment sites and centres. The QCTO already realise that they cannot design and develop all the assessment instruments that will be needed in the near future, so they are currently much more flexible and willing to adopt more realistic options, such as allowing assessment centres to design and develop assessment instruments based on assessment specifications written by DQPs in cooperation with AQPs. At the same time they are still thinking in terms of charging fees for AQP services. It is not clear what they will charge fees for, but one can imagine that there will be external moderation and perhaps, assessment of integrated summative assessments testing exit level outcomes at the end of learning programmes.

The most obvious place that private learning providers can and should take up in relation to the QCTO is – exactly what they have been doing all these years, namely just to accredit and offer learning. You will be surprised at how well most of the QCTO officials appreciate the work being done by private ETD providers. The only possible stumbling block is the process of accreditation which has been adapted to the QCTO structure. From this emanated a number of criteria contextualised to the occupational arena and articulated to the general spirit of the NQF. I am not a QCTO official, so I am in no position to propagate policy on their behalf. Therefore the following is just my opinion. I believe that, in addition to the “standard” criteria relating to capacity, private providers will need to do the following in order to accredit with the QCTO:

Accredit for full national qualifications with the ETQA with which you are accredited now already. The QCTO appreciates that there is a need for part qualifications, specifically short courses and they are working on this, but it would be prudent to obtain proper accreditation now already, because it would be really difficult, probably impossible, to register with the DHET if you offer less than full qualifications and you will not be allowed to offer official learning programmes if you are not registered by the DHET.

Negotiate with one or more universities and/or public FET colleges to offer learning programmes in association with them. This will not be easy because there simply are not enough funds going around to sustain both the public institutions and private learning providers. It will take really good entrepreneurship to solve this one.

Make sure that you will be able to offer the workplace learning (experiential learning) part of qualifications in addition to the traditional contact or distance learning that you currently offer. Your SETA might be able to arrange this, but SETAs are now paying much more attention to public learning institutions, and it will take some time before they realise their mistake.

Make sure that you have the capacity in terms of finances, resources, professional staff and infrastructure to offer best quality education, training and development.

In closing, the QCTO officials to whom I spoke are acutely aware of the important role that private providers play in the development of the South African community. They do not have in mind closing down private providers, so they are not exclusively to blame for the turbulent times in which we are finding ourselves. There are some areas in which private providers can play a role, for example as part of the stakeholders in OETD, the so-called Community of Expert Practitioners (CEPs); in registering as OQDF or assessment centres or sites or both; as consultants in the further development of the QCTO model and as accredited ETD providers.

The QCTO is also very open-minded about their model and nothing is really cast in concrete yet. For example, the QCTO will also need to submit qualifications in the format prescribed by SAQA (Policy Document 1340/00: Criteria and Guidelines for the Generation and Evaluation of Qualifications and Standards within the National Qualifications Framework, Revision 4 – 23 August 2005), and the current computer-based curriculum model does not meet these requirements. I will not be surprised if they go back to the curriculum model used by the CHE/HEQC or perhaps even the unit standard-based format.

This implies that they might also rethink the idea of using OQDFs – I sincerely hope so, since this is a hugely deficient structure. I am not so sure that we have seen the end of the old unit standards – there are those in the QCTO and SAQA who, like me and many other learning providers, firmly believe in the merits of unit standards, and they might just listen to reason. And yes, the more private providers join The Mentoring Network the easier will it be to protect and promote the interest of private providers with DHET, SAQA and the quality assurance bodies.

Do you know anything about Private service providers who provide short courses (one or two or three unit standards) for clients where the client will NEVER require their employees to get the full qualification.

Some examples of this: In the field of Health and Safety - first aid courses, safety rep courses, Peer educator courses (either HIV or wellness related) or counsellor training for nurses either generic counselling or HIV counselling. The full qualification will never be paid for by the client. They only want their employees to have the skills and knowledge provided by the unit standard.

There is absolutely no reason for us as a training provider to spend all those hours and money to gain accreditation for the full qualification if we would never use the full qualification and do not have the staff to develop or facilitate most of the fundamental unit standards.

Your arguments are very relevant, Linzi, and I hope the quality assurance bodies keep in mind that there are other (real) skills needs in the industry apart from their cloud nomber 9. I am confident that reason will prevail, but in this day an age you never know... JPN

Linzi Smith said:

Thanks for the explanation Johannes.

Do you know anything about Private service providers who provide short courses (one or two or three unit standards) for clients where the client will NEVER require their employees to get the full qualification.

Some examples of this: In the field of Health and Safety - first aid courses, safety rep courses, Peer educator courses (either HIV or wellness related) or counsellor training for nurses either generic counselling or HIV counselling. The full qualification will never be paid for by the client. They only want their employees to have the skills and knowledge provided by the unit standard.

There is absolutely no reason for us as a training provider to spend all those hours and money to gain accreditation for the full qualification if we would never use the full qualification and do not have the staff to develop or facilitate most of the fundamental unit standards.

Do you know anything about Private service providers who provide short courses (one or two or three unit standards) for clients where the client will NEVER require their employees to get the full qualification.

Some examples of this: In the field of Health and Safety - first aid courses, safety rep courses, Peer educator courses (either HIV or wellness related) or counsellor training for nurses either generic counselling or HIV counselling. The full qualification will never be paid for by the client. They only want their employees to have the skills and knowledge provided by the unit standard.

There is absolutely no reason for us as a training provider to spend all those hours and money to gain accreditation for the full qualification if we would never use the full qualification and do not have the staff to develop or facilitate most of the fundamental unit standards.

As a point of interest I applied to QCTO on the advice of ETDP SETA to register as a OQDF. Guess what I was referred back to the SETA by the QCTO. I have now contacted both to seek clarification and am unfortunately (not surprising) receiving no response whatsoever.

The same applies to registering as an AQP - I was referred back to SETA and once again I am at a standstill.

In Feng Shui, which is concerned with enabling the movement of good energy within structures, there is advice never to put a mirror at both ends of a corridor or passage. This is because the energy will be trapped and simply move back and forwards, therefore not providing any good energy anywhere else in the building. This seems to very effectively describe the current QCTO - providing no enlightenment or good energy to the ETD structures.